How do you deal with the challenges of applying the arm's length principle to intra-group services?
If you are involved in transfer pricing, you know that the arm's length principle is the cornerstone of the international tax system. It requires that transactions between related parties are priced as if they were independent entities. However, applying this principle to intra-group services, such as management, IT, or R&D, can be challenging. In this article, you will learn how to deal with some of the common issues that arise when determining the arm's length remuneration for intra-group services.